AML/KYC & Customer Acceptance Policy

This AML / KYC / Document Verification / Client Acceptance and Service Refusal Policy ("Policy") establishes the principles for reasonably evaluating the identity, authority, activities, documents, and transaction reliability of natural and legal persons requesting services through the kosovainvestment.com platform.\n\nThe purposes of this Policy are specifically:\n\nto ensure services are provided in a lawful and secure manner,\nto reduce identity theft, fraud, document manipulation, and misuse,\nto detect risky, illegal, or suspicious transaction requests,\nto understand who the customer is and in what capacity they are acting,\nto perform basic authority checks for companies and representatives,\nto conduct service eligibility assessments,\nto request additional documents when necessary,\nto refuse, suspend, or terminate service when warranted.\n\nThis Policy does not claim to be an official financial institution compliance handbook; it is a private sector-based risk, identity, and document control framework designed to suit the platform's service model.

This Policy applies to the following persons and transactions on the platform:\n\nusers creating accounts,\npersons requesting quotes,\ncustomers making payments,\nusers uploading documents,\nthose requesting company formation or amendment services,\nthose using business address / registered office address,\nthose requesting accounting or operations coordination,\nthose receiving application file or document preparation services,\nthose transacting on behalf of a company, shareholder, director, representative, proxy, or third party.\n\nThe Company is not obligated to conduct the same level of scrutiny for every service type. Lighter or more intensive verification may be applied depending on the risk level.

The Company adopts the following fundamental principles in client acceptance and document verification processes:\n\n3.1. Risk-Based Approach\n\nNot every customer and transaction carries the same level of risk. Therefore, the level of control may vary based on the nature of the service, the country, the document type, the purpose of the transaction, the company structure, and concrete risk indicators.\n\n3.2. Purpose Limitation\n\nInformation and documents requested shall, as a rule, be limited to the purposes of service delivery, ensuring security, understanding identity and authority, preventing fraud, and legal compliance.\n\n3.3. Proportionality\n\nThe Company aims to avoid unnecessary or excessive data collection; however, if the nature of the service requires detailed documentation, more comprehensive document requests may be deemed reasonable.\n\n3.4. Professional Discretion\n\nThe Company has reasonable discretion regarding the sufficiency, consistency, reliability, and risk level of information and documents presented to it.\n\n3.5. Freedom to Choose Services\n\nThe Company is not obligated to provide service to every customer under all circumstances. It may refuse service in cases of illegality, risk, suspicion of fraud, lack of cooperation, or reputational/security risk.

4.1. AML\n\nFor the purposes of this Policy, AML essentially refers to fundamental risk sensitivity regarding money laundering, use of illegal funds, fraud, misuse of identity and corporate structures, forgery, misleading transaction schemes, and illegal commercial arrangements.\n\n4.2. KYC\n\nKYC ("Know Your Customer") refers to the process of reasonably understanding who the customer is, in what capacity they are acting, for what purpose they are requesting the service, and, when necessary, on whose behalf they are acting.\n\n4.3. Document Verification\n\nRefers to the formal, logical, and where necessary source-based verification of documents and information presented by the customer. This verification does not imply an unlimited and absolute guarantee of accuracy.\n\n4.4. Risk Indicator\n\nAny element that appears unusual, contradictory, unexplained, or suspicious in terms of the transaction, customer, document, payment, communication, or behavior may be considered a risk indicator.\n\n4.5. Beneficial Owner / Ultimate Controller\n\nRefers to the natural person who may have direct or indirect actual control over a company, structure, or transaction.

The Company may request some or all of the following information and documents depending on the nature of the service:\n\n5.1. From Natural Persons\nfull name,\ndate of birth,\nnationality,\npassport or ID copy,\nselfie / ID verification / video verification-type confirmation methods,\naddress information,\naddress verification document,\nphone number,\nemail address,\nservice purpose declaration,\nexplanation regarding the source of funds or purpose of transaction if deemed necessary.\n\n5.2. From Companies\ncompany name,\nregistration number,\ncountry of incorporation,\nbusiness activity,\nincorporation documents,\nownership structure,\nshareholder list,\ndirector/authorized person information,\ntax number,\nauthorized signatory information,\npower of attorney documents if applicable.\n\n5.3. From Representatives and Third Parties\npower of attorney or authorization letter,\nidentity of the principal,\nrelationship between the parties,\npurpose of the transaction.

The Company may apply one or more of the following methods for identity verification:\n\nverification of identity document (passport, ID card) copy,\nselfie + ID comparison,\nvideo call verification,\nemail verification,\nphone verification,\naddress verification (utility bill, bank statement),\ncompany registry verification,\ncross-referencing information from different sources.\n\nThe verification method may vary depending on the service type, transaction amount, risk level, and country of origin.

For services requested on behalf of companies, the Company may additionally:\n\nreview the company's registration and current status,\nverify the identity of the person authorized to act on behalf of the company,\ncheck the ownership structure and shareholder list,\nrequest documentation regarding beneficial owners,\nassess whether the company's declared business activity is consistent with the requested service,\nrequest additional documents if the company structure appears complex or opaque.

The following situations may be considered risk indicators:\n\nthe customer refusing to provide basic identity information,\nsubmission of forged, altered, or inconsistent documents,\nrequesting services for purposes inconsistent with the company's declared activities,\na discrepancy between the person making payment and the service beneficiary,\nexcessive urgency or pressure to expedite processes,\nrequests to circumvent standard procedures,\ninvolvement of politically exposed persons,\ncomplex or opaque ownership structures,\nrequests from sanctioned countries or persons,\ninconsistencies in the information provided at different stages,\ncommunication patterns suggesting the customer is acting on behalf of an undisclosed third party,\nrefusal to explain the source of funds or purpose of transaction,\nrequests that could facilitate tax evasion, fraud, or money laundering,\nattempts to structure transactions to avoid reporting thresholds,\nany other circumstance that raises reasonable suspicion.

In the presence of risk indicators, the Company reserves the right to:\n\nrequest additional identity documents or verification,\nask for a detailed explanation regarding the purpose of the transaction,\nrequest documentation regarding the source of funds,\nseek third-party verification or official records,\npostpone service delivery until additional verification is completed,\napply enhanced monitoring during and after service delivery.

The Company may refuse to provide service if:\n\nthe customer fails to provide requested identity information or documents,\nsubmitted documents appear forged, altered, or unreliable,\nthe purpose of the service appears to be illegal or contrary to public policy,\nrisk indicators cannot be resolved through additional scrutiny,\nthe customer fails to cooperate with verification procedures,\nthe service request falls outside the Company's service scope,\nproviding the service could pose reputational, legal, or operational risk to the Company.\n\nRefusal of service does not require detailed justification to the customer.

The Company may suspend an ongoing service if:\n\nnew risk indicators emerge during service delivery,\nthe customer fails to respond to requests for additional information,\nthird-party information suggests the customer's declarations may be inaccurate,\nregulatory changes require additional review.\n\nSuspension may be temporary pending resolution or may lead to termination.

The Company may request explanation from the customer regarding:\n\nthe purpose and nature of the requested service,\nthe source of funds,\nthe relationship between parties to a transaction,\ninconsistencies in submitted documents or information.\n\nThe customer is expected to respond to such requests in good faith and within a reasonable timeframe. Failure to respond may result in service refusal or suspension.

The platform may not be used for:\n\nmoney laundering or terrorist financing,\ntax evasion or aggressive tax avoidance schemes,\nfraud, forgery, or identity theft,\ncircumvention of international sanctions,\nany activity prohibited under Kosovo law or applicable international regulations,\nestablishing shell companies with no genuine business purpose,\nany activity that could harm the platform's reputation or integrity.\n\nThe Company reserves the right to refuse and report any attempt to use the platform for these purposes.

For business address services, the Company applies additional scrutiny as addresses can be misused for:\n\nfraudulent company registrations,\nshell company formations,\ntax evasion schemes,\nidentity concealment.\n\nThe Company may require additional documentation, explanation of business purpose, and may conduct periodic reviews of address service users. The Company reserves the right to terminate address services if the address appears to be used for purposes inconsistent with genuine business activities.

If there is a discrepancy between the person making payment and the service beneficiary, the Company may:\n\nrequest an explanation for the discrepancy,\nrequire authorization from the service beneficiary,\nrefuse to process the payment,\nsuspend service delivery until the discrepancy is resolved.\n\nPayments from unverified or suspicious sources may be refused.

The Company reserves the right to maintain internal records and notes regarding:\n\ncustomer verification processes,\nrisk assessments,\ndocument verification results,\nreasons for service refusal or suspension,\ncommunication with customers regarding verification matters.\n\nSuch records are maintained for the Company's legitimate interests and in accordance with applicable data protection regulations.

Information collected under this Policy is processed in accordance with the Company's Privacy Policy and applicable data protection legislation.\n\nData collected for AML/KYC purposes is used solely for the purposes stated in this Policy and is not shared with third parties except as required by law or regulatory obligation.\n\nCustomers have the right to access, correct, and request deletion of their personal data subject to legal retention requirements.

In cases where the Company suspects illegal activity, it reserves the right to:\n\nrefuse service without providing detailed explanation,\nlimit the information disclosed to the customer regarding the reasons for refusal,\nreport suspicious activities to relevant authorities as required by law.\n\nThis provision exists to protect the integrity of anti-money laundering efforts and to comply with legal obligations.

If risk indicators emerge after the service relationship has been established, the Company may:\n\nrequest additional verification,\nsuspend ongoing services,\nterminate the service relationship,\nretain documents and information as required by law.\n\nThe emergence of new risk indicators does not obligate the Company to complete previously agreed services.

In the event of service refusal or suspension:\n\nfees for work already completed are non-refundable,\nif a significant portion of the service has been completed, a proportional fee may be retained,\nrefunds, if applicable, will be processed in accordance with the Company's Refund Policy,\ngovernment fees, third-party costs, and external expenses already incurred are non-refundable.

By using the platform and requesting services, the user declares that:\n\nall information provided is accurate and complete,\nthey are not acting for illegal purposes,\nthey will cooperate with verification procedures,\nthey understand that false declarations may result in service termination and legal consequences,\nthey have read and accepted this Policy.

I have read and accept the AML / KYC / Document Verification / Client Acceptance and Service Refusal Policy. I declare that the information I provide is accurate and complete, and I consent to the verification procedures described in this Policy.\n\nI understand that kosovainvestment.com (KS Law Consultancy LLC) reserves the right to request additional documents, refuse service, or suspend transactions if risk indicators are identified or if I fail to cooperate with verification procedures.

Notice: All services provided through kosovainvestment.com are subject to our AML / KYC / Document Verification / Client Acceptance and Service Refusal Policy. We reserve the right to request additional identity verification, documents, or explanations, and to refuse or suspend services if we identify risk indicators or compliance concerns.\n\nBy proceeding with any service request, you confirm that you have read, understood, and accepted our Policy.

This Policy is governed by and construed in accordance with the laws of the Republic of Kosovo. Any disputes arising from or related to this Policy shall be subject to the exclusive jurisdiction of the courts of the Republic of Kosovo.

For questions or concerns regarding this Policy:\n\nKS Law Consultancy LLC\nEmail: [email protected]\nWebsite: kosovainvestment.com

This Policy may be updated from time to time without prior notice. The most current version is always available on the platform. Continued use of the platform after updates constitutes acceptance of the revised Policy.\n\nLast updated: 2025